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IN THE UNITED STATES DISTRICT COURT 

 FOR THE EASTERN DISTRICT OF PENNSYLVANIA

GRACE LAWRENCE 

Plaintiff, 

v. 

TRANS UNION LLC 

CITY OF PHILADELPHIA 

Defendant. 

C.A. NO: 02-CV-4440 

 DEFENDANT=S UNOPPOSED EMERGENCY 

 MOTION TO CONTINUE TRIAL 

Trans Union LLC, by and through its undersigned attorneys, files the instant motion and 

Declaration in support of its request to continue trial and states as follows: 

1. Last week, counsel for Trans Union was informed that Eileen Little, 

Consumer Relations Group Manager and corporate representative for trial purposes, was seriously ill 

and is taking a medical leave until at least March 1, 2004 at which time her condition and ability to 

return to work will be re-evaluated. (See Exhibit “A” hereto, Declaration of Bruce S. Luckman, 

Esq., and Exhibit “B” hereto letter from, Nicholas A. Busillo, M.D.) As such, Ms. Little is not (and 

has not been) available to prepare for or attend the trial of this action and will likely not be available 

until in or about April 2004. For the following reasons, Trans Union respectfully requests that the 

trial be continued. 

2. Ms. Little has been an employee of Trans Union for over twenty five years 

and for the last twelve has acted as liaison with undersigned counsel for litigation purposes. 

3. Moreover, her testimony in this particular action is crucial in connection with 

consumer disclosures, dispute reinvestigation procedures and, generally, a knowledge of Trans 

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Union’s business and FCRA compliance practices and procedures. 

4. As such, Ms. Little is crucial Trans Union=s defenses and explanation of the 

parts of FCRA compliance processes challenged by plaintiff=s claims. 

5. James Francis, trial counsel for plaintiff, deposed Ms. Little. Ms. Little is 

identified on the witness list of plaintiff and defendant. Plaintiff has (or no doubt will) serve a 

subpoena to require Ms. Little to appear at trial. 

6. Trans Union will be prejudiced if it has to conduct the trial of this action 

without Ms. Little because there is no other witness familiar with the relevant procedures and the 

facts and circumstances of this action who can testify. Further, if Ms. Little is not available, Trans 

Union will be prejudiced because plaintiff may use the Little deposition at trial and Trans Union will 

not be in a position to call Ms. Little to explain or support the understandably one sided cross 

examination of a non-trial deposition. 

7. Because of Ms. Little’s illness, she has not been available to prepare with 

counsel or to assist in preparing a substitute witness. 

8. Trans Union respectfully requests that the trial of this action be continued for 

sixty (60) days. 

9. Mr. Francis does object to the instant request for a continuance of the trail. 

10. If the Court is inclined to adjourn the trial, Trans Union and its counsel remain 

available for a settlement conference, or for other purposes determined by the Court which can serve 

judicial economy. 

11. This request is made in good faith and solely for the purpose of allowing Ms. 

Little to treat her illness and fully recover and not for purposes of delay. Undersigned counsel will 

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promptly notify the Court and plaintiff is there is a material change in Ms. Little’s expected return to 

full duty. 

12. The sought adjournment will not prejudice any party. 

Wherefore, defendant respectfully submits that Trans Union LLC=s unopposed motion 

should be granted. 

 Respectfully Submitted, 

 ______________________________ 

 BRUCE S. LUCKMAN (38636) 

TIMOTHY P. CREECH (81728) 

SATZBERG, TRICHON, 

 KOGAN & WERTHEIMER, P.C. 

1818 Market St., 30th Floor 

Philadelphia, PA 19103 

(215) 575-7600; Fax: (215) 575-7688 

bluckman@mstkw.com

tcreech@mstkw.com

Attorneys for Defendant, 

Trans Union LLC 

DATED: February 17, 2004 

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